Policy Statements » Letters from the President:

Re: September
9, 2004 draft Biological Opinion on the operations of the Federal Columbia River
Power System

Dear Ms. Howard:

The Ecological Society of America
(ESA), the nation’s professional society of ecological scientists, wishes to
offer comments on the draft Biological Opinion (BiOp) for Columbia and Snake
River Basin salmon and steelhead.

Restoring wild salmon and steelhead
to self-sustaining, harvestable populations is a national priority and of great
economic significance to the Pacific Northwest region. The ESA is seriously
concerned that the draft plan abandons recovery as an objective, and is unlikely
to recover wild populations from risk of extinction, let alone restore healthy
populations.

In contrast to previous decisions,
the new draft BiOp claims that the operation of the Federal Columbia River Power
System (FCRPS) does not jeopardize protected salmon and steelhead, and requires
only that certain proposed operations do not appreciably reduce survival. It
treats federal dams as immutable parts of the environment, yet this ignores the
extent to which the dams have detrimentally altered the Columbia Basin
ecosystems and contributed to fish population declines. Dam removal and other
aspects of ecosystem restoration should be considered as potential options for
mitigation; otherwise, federal efforts are unlikely to recover endangered
populations.

The ESA is concerned that the
draft’s proposed actions instead rely on expensive strategies whose benefits to
fish populations are speculative at best. For example, it remains unclear
whether the addition of removable spillway weirs or downstream transportation of
juvenile fish will appreciably boost fish survival. The BiOp should place
greater emphasis instead on science-based restoration of salmon to their natural
habitat.

Additionally, the draft BiOp gives
undue weight to recent, relatively higher salmon returns in the Columbia Basin.
Although adult return rates have increased since 2001, this has been credited by
scientists to temporary ocean conditions and not to management strategies.
There is no scientific justification to conclude that current restoration
efforts are sufficient, or that they can be relaxed.

In conclusion, a commitment to
restoring self-sustaining harvestable populations of wild salmon and steelhead
should be the cornerstone of federal salmon strategies. The weight of
scientific evidence points to the harmful impacts of FCRPS operations. Hence,
the total impact of these dams should be taken into account in any federal
strategy. The Ecological Society of America supports the impartial
consideration of all available and scientifically sound options to recover
salmon and steelhead populations, including but not limited to the removal of
dams from the Columbia and Snake rivers. We urge you to revise this draft to
ensure significant recovery of the Pacific Northwest’s wild salmon and
steelhead.